1.0 Purpose

To ensure the safety of all personnel required to work in confined spaces

2.0 Scope

All business locations under HSC control where there are work areas that have been classified as confined spaces identified via the risk assessment process.

3.0 Definitions / Term Definition

Authorized Person: A person appointed to carry out specific duties

Competent Person: Persons trained, experienced and authorized to carry out a particular function

Confined Space: A space or structure that is, large enough that employees can bodily enter and perform work and is not designated for continuous occupancy and has limited openings for entry and exit and restricted natural ventilation, e.g. oil storage tanks, reaction vessels, inside furnace, inspection pits, etc.

LFL (Lower Flammable Limit): the concentration in air at or below which a flammable substance will not burn when exposed to a source of ignition.

OEL (Occupational Exposure Limit): The maximum exposure a person can have to a chemical without known side effects.

PTW: Permit to Work

4.0 Responsibilities

4.1 Site Manager

Ensure that arrangements are in place to enable compliance with the requirements of this procedure

4.2 Site HSE Representative

Ensure that that this Procedure is audited at appropriate intervals

Ensure that a PTW System is in place

Ensure that Confined space Resister is prepared and maintained

5.0 Process

5.1 Alternative Methods

The decision to enter a confined space must be a last resort after having considered work practices where entry would not be required i.e. could the confined space itself be modified so that entry is not necessary; could the work done from outside (e.g. inspection, sampling and cleaning operations can often be done from outside the space using appropriate equipment and tools; remote cameras can be used for internal inspection of vessels)

5.2 Confined Space Register

A written inventory of all confined spaces must be established and maintained for the site. A register of all staff and Sub-Contractors who are trained to perform work in confined spaces must also be established and maintained.

5.3 Training

Everyone involved with preparation of confined spaces for entry; those required to enter a confined space, Watchers and those that may have to enter in the event of an emergency must be given appropriate training.

The person responsible for the completion of a confined space entry permit and / or the Authorized Person must be suitably trained and competent within the permit system, confined space entry requirements and the hazards associated with the work

Training must provide details of the risk assessment and will include as a minimum:

Confined space entry permits

Use of barriers to prevent unauthorized entry

Emergency entry and exit procedures iv. Use of respiratory equipment.

Use of Safety Equipment

Communication, including marking / identification of confined spaces

Rescue drills

Fire protection

5.4 Risk Assessment

If entry to a confined space is unavoidable a safe system of work and adequate emergency arrangements must be in place before the work starts. The first step will be to perform a suitable and sufficient Risk Assessment in order to identify any hazards, assess the risk and determine precautions. The following must be taken into consideration: a. The task being performed

The working environment

Working material and tools

The suitability of those carrying out the task

Arrangements for emergency rescue

5.5 Hazards to be Considered

5.5.1 If the atmosphere in the confined space contains toxic, flammable / explosive substances, carbon monoxide gas, corrosive substances and/or low/ high oxygen levels, the confined space must be emptied and flushed or purged. Fresh air (normal air in sufficient quantity to make the atmosphere safe) must be provided. If this cannot be achieved, or if there is a risk that an inappropriate atmosphere could evolve during the work, self-contained breathing apparatus or air hoods must be used along with other protective measures such as ensuring that ignition sources or materials that may inadvertently cause ignition are not taken into the confined space or the vicinity of an opening to the confined space.

Note: respirators must not be used if there is a risk of oxygen deficiency.

5.5.2 When providing fresh air, it must be ensured that the fresh air intake is not contaminated by smoke, exhaust fumes from generator sets, etc. and that the intake is protected from interference. Open vents must be prevented from being closed or obstructed and air blowers/extractors must be safeguarded against disconnection. Forced ventilation such as air blowers must be fitted with an alarm that will activate in the event of a breakdown of the equipment or alternatively the equipment doubled up or a person on standby close to the equipment. In the event of hearing the failure alarm or being alerted by the person on standby, the confined space must be immediately evacuated.

5.5.3 Under no circumstances must oxygen be used to provide breathable air or to sweeten the atmosphere. An oxygen-enriched atmosphere presents a serious risk of fire and explosion and can cause normally stable materials to become highly combustible e.g.

grease can become liable to spontaneous combustion when oxygen-enriched.

5.5.4 If welding or burning must be conducted in the confined space consideration must be given to the fact that the process could seriously reduce the breathable air and introduce toxins.

5.5.5 Flammable substances and substances liable to give off gases, vapors or fumes including substances being used in the confined space e.g. paints, resinous compounds etc., must be continuously monitored to ensure that the OEL and LFL are not exceeded.

5.5.6 Gas/oxygen cylinders must not be taken into a confined space. If gases, such as acetylene / oxygen, are required for welding or combustion, and the gas must be carried by cylinders outside a limited space and hoses of continuous length. When not in use the gas/oxygen supply must be turned off at the nozzle/torch and cylinders and the hoses disconnected from the cylinders or completely removed from the confined space after each shift.

5.5.7 Consideration must also be given to the tools, plant and equipment being taken into the confined space e.g., if a flammable atmosphere, all electrical equipment/appliances must be explosive proof or intrinsically safe, tools will need to be non-metallic and all other sources of ignition prohibited. Smoking is prohibited in all confined spaces

5.5.8 Consideration must also be given to noise that may be generated from the work inside the confined space and any work taking place on external surfaces of the confined space or adjoining plant/apparatus. Noise in a confined space tends to reverberate and intensify. Therefore, noise that sounds to be at an acceptable level outside could be unacceptable inside. When considering what action to take with respect to protecting persons inside a confined space from a noise source, it must be appreciated that ear protection may make it difficult for them to communicate with persons on standby duty on the outside.

5.6 Confined Space Entry

5.6.1 Only Competent Persons will enter confined spaces. An Entry Log (or equivalent) must be used to identify the persons inside the confined space at any time.

5.6.2 Entry into a confined space may only be carried out under a permit to work. Prior to a PTW being issued the following information must be taken into account:

A suitable and sufficient risk assessment must have been undertaken. Any requirements for improvement must be carried out before the risk assessment and method statement are accepted.

The confined space must be isolated from the system. The physical opening of pipes and ducts, leaving an air gap between the supply of materials and the confined space is the preferred method but it is recognized that this is not always practical. Blanks may be fitted or suitable valve locked shut

Tests must be carried out to determine if the confined space is oxygen deficient and/or contains flammable substances, toxic agents, carbon monoxide and/or harmful physical agents. Any sludge or deposits that might be disturbed by personnel in the confined space must be stirred up before the tests are carried out. In the event that sources of possible supply could not be opened to the atmosphere, then continuous monitoring is necessary.

5.6.3 A suitably trained person (Watcher) must be on standby outside the confined space entry point to ensure that in the event of an accident inside the confined space, this person can raise the alarm. Communication with the persons working in the confined space must be established and monitored by the person on watch duty

5.6.4 The Watcher must:

Be able to account for everyone in the confined space at any time

Not enter the confined space

Not be involved at any other work activity whilst on watch

5.6.5 Where appropriate, persons entering a confined space must wear approved fall protection equipment. A lifeline must be securely attached to the outside of the confined space. When considering the use of lifelines, the complexity of the confined space needs to be taken into account to ensure that the lifeline will be of assistance in an emergency and not present a hazard. If entanglement is an issue the line should still be lowered into the space complete with securing hook – ready for use

5.6.6 The watcher or rescue personnel with breathing apparatus must be available at all times.

5.6.7 If a hazard that was not taken into account in the original risk assessment emerges or if conditions within the confined space change, the person in charge of the work in the confined space must withdraw all personnel and report the matter to the HSC Site Representative.

5.7 Closing a Confined Space

Before closing confined spaces, the person in charge of the work must remove all personnel, tools, and equipment from confined spaces. All members of the confined space working party must be accounted for and a physical inspection carried out.